FPC INVESTMENT ADVISORY, INC.

ITEM 1 - COVER PAGE ADV PART 2A BROCHURE FPC INVESTMENT ADVISORY, INC. 1465 N. MCDOWELL BLVD. #170 PETALUMA, CA 94954 P/ 707.795.0500 W/ FPCWEALTH.COM November 20, 2025 This brochure provides information about the qualifications and business practices of FPC Investment Advisory, Inc. (“FPC”). If you have any questions about this brochure's contents, please contact us at (707) 795-0500. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or any state securities authority. FPC is a Registered Investment Adviser (“RIA”). Registration as an Investment Adviser with the SEC or any state securities authority does not imply a certain level of skill or training. Additional information about FPC is available on the SEC's website at http://www.adviserinfo.sec.gov/. You can search this site by a unique identifying number called an IARD number. The IARD number for FPC is 122728. FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 1 of 27  ITEM 2 - MATERIAL CHANGES SUMMARY OF MATERIAL CHANGES Under federal and state law, fiduciaries must make full disclosure to Clients of all material facts relating to the advisory relationship. This brochure provides clients or prospective clients with information and conflicts of interest about FPC Investment Advisory that should be considered before or when obtaining our investment advisory services. We are required to update this item to describe the material changes made to this brochure on an annual basis and deliver to you, within 120 days of the end of the fiscal year, a free updated brochure that includes or is accompanied by a summary of material changes; or a summary of material changes and an offer to provide an updated brochure and how to obtain it. We will also provide interim disclosures regarding material changes, as necessary. Since the last annual amendment filing on November 8, 2024 the following material changes have been made: • Item 5: Our fee schedule has been updated. This brochure may be updated periodically for non-material changes to clarify and provide additional information. QUESTIONS & CONCERNS We encourage you to read this document in its entirety. Our Chief Compliance Officer, Bijan Golkar, remains available to address any questions or concerns regarding this Part 2A Brochure, including any material change disclosure or information described below. FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 2 of 27  ITEM 3 - TABLE OF CONTENTS ITEM 1 - COVER PAGE ____________________________________________________________________________ 1 ITEM 2 - MATERIAL CHANGES ____________________________________________________________________ 2 SUMMARY OF MATERIAL CHANGES ___________________________________________________________ 2 QUESTIONS & CONCERNS ____________________________________________________________________ 2 ITEM 3 - TABLE OF CONTENTS ___________________________________________________________________ 3 ITEM 4 - ADVISORY BUSINESS _____________________________________________________________________ 6 ABOUT OUR FIRM ____________________________________________________________________________ 6 ADVISORY SERVICES WE OFFER _______________________________________________________________ 6 LEGACY MANAGEMENT SERVICES __________________________________________________________________ 7 FINANCIAL PLANNING SERVICES ____________________________________________________________________ 7 INCOME TAX PREPARATION SERVICES ______________________________________________________________ 7 CONSULTING SERVICES & ASSETS UNDER ADVISEMENT ______________________________________________ 7 ROLLOVER RECOMMENDATION DISCLOSURE ________________________________________________________ 8 CLIENT OBJECTIVES & RESTRICTIONS _________________________________________________________ 8 WRAP FEE PROGRAM ________________________________________________________________________ 8 ASSETS UNDER MANAGEMENT _______________________________________________________________ 9 ITEM 5 - FEES AND COMPENSATION ______________________________________________________________ 9 INVESTMENT MANAGEMENT FEE _____________________________________________________________ 9 LEGACY MANAGEMENT FEE _______________________________________________________________________ 10 FINANCIAL PLANNING FEE ________________________________________________________________________ 10 TAX PLANNING SERVICE FEES _____________________________________________________________________ 11 CONSULTING SERVICES & ASSETS UNDER ADVISEMENT FEE _________________________________________ 11 ADMINISTRATIVE SERVICES PROVIDED BY TAMARAC, INC. ____________________________________ 11 ADDITIONAL FEES & EXPENSES _____________________________________________________________ 11 ITEM 6 - PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT _____________________________ 12 ITEM 7 - TYPES OF CLIENTS ____________________________________________________________________ 12 ITEM 8 - METHODS OF ANALYSIS, STRATEGIES, & RISK OF LOSS ___________________________________ 13 METHODS OF ANALYSIS ____________________________________________________________________ 13 CYCLICAL TACTILE ASSET ALLOCATION ____________________________________________________________ 13 RISK OF LOSS ______________________________________________________________________________ 14 ACTIVE MANAGEMENT RISK _______________________________________________________________________ 14 ALLOCATION RISK ________________________________________________________________________________ 14 FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 3 of 27  CAPITALIZATION RISK _____________________________________________________________________________ 14 COMPANY RISK ___________________________________________________________________________________ 14 CONCENTRATION RISK ___________________________________________________________________________ 14 CREDIT RISK ______________________________________________________________________________________ 14 CYBERSECURITY RISK ______________________________________________________________________________ 15 DEFLATION RISK __________________________________________________________________________________ 15 EQUITY RISK ______________________________________________________________________________________ 15 EVENT RISK _______________________________________________________________________________________ 15 INTEREST RATE RISK ______________________________________________________________________________ 15 LEGACY HOLDING RISK ___________________________________________________________________________ 15 LIQUIDITY RISK ___________________________________________________________________________________ 16 MANAGEMENT RISK ______________________________________________________________________________ 16 MARKET RISK _____________________________________________________________________________________ 16 MUTUAL FUND OR ETF RISK _______________________________________________________________________ 16 REINVESTMENT RISK ______________________________________________________________________________ 16 SECTOR RISK _____________________________________________________________________________________ 16 ITEM 9 - DISCIPLINARY INFORMATION __________________________________________________________ 17 ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS _______________________________ 17 ITEM 11 - CODE OF ETHICS, PARTICIPATION & INTEREST IN CLIENT TRANSACTIONS, & PERSONAL TRADING _____________________________________________________________________________________ 17 PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS & PERSONAL TRADING ______________________ 17 ITEM 12 - BROKERAGE PRACTICES ______________________________________________________________ 18 INVESTMENT MANAGEMENT SERVICES ______________________________________________________ 18 CHARLES SCHWAB & CO. INC. ______________________________________________________________ 18 HOW OUR FIRM SELECTS CUSTODIAN-BROKER _____________________________________________________ 18 CLIENT BROKERAGE & CUSTODY COSTS ___________________________________________________________ 19 PRODUCTS AND SERVICES AVAILABLE TO US FROM SCHWAB ________________________________________ 19 SERVICES THAT BENEFIT OUR CLIENTS _____________________________________________________________ 19 SERVICES THAT MAY NOT DIRECTLY BENEFIT OUR CLIENTS __________________________________________ 19 SERVICES THAT GENERALLY BENEFIT ONLY US ______________________________________________________ 20 OUR INTEREST IN SCHWAB’S SERVICES _____________________________________________________________ 20 BROKERAGE FOR CLIENT REFERRALS _______________________________________________________________ 21 AGGREGATION & ALLOCATION OF TRANSACTIONS _________________________________________________ 21 TRADE ERRORS ___________________________________________________________________________________ 22 DIRECTED BROKERAGE ___________________________________________________________________________ 22 FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 4 of 27  ITEM 13 - REVIEW OF ACCOUNTS _______________________________________________________________ 22 CLIENT REVIEWS ___________________________________________________________________________ 22 ITEM 14 - CLIENT REFERRALS & OTHER COMPENSATION _________________________________________ 23 BROKERAGE PRACTICES ____________________________________________________________________ 23 OTHER PROFESSIONALS ___________________________________________________________________________ 23 ITEM 15 - CUSTODY ____________________________________________________________________________ 24 FEE DEDUCTION ___________________________________________________________________________ 24 STANDING LETTERS OF AUTHORIZATION (“SLOA”) ___________________________________________ 24 ITEM 16 - INVESTMENT DISCRETION ____________________________________________________________ 24 DISCRETIONARY AUTHORITY _______________________________________________________________ 24 ITEM 17 - VOTING CLIENT SECURITIES ___________________________________________________________ 25 PROXY VOTING ___________________________________________________________________________________ 25 CLASS ACTION LAWSUITS _________________________________________________________________________ 25 ITEM 18 - FINANCIAL INFORMATION ____________________________________________________________ 26 FINANCIAL CONDITION ____________________________________________________________________ 26 ADDITIONAL INFORMATION ___________________________________________________________________ 26 PRIVACY POLICY ___________________________________________________________________________ 26 OPTING OUT _____________________________________________________________________________________ 26 BUSINESS CONTINUITY PLAN _______________________________________________________________ 26 CONTACTING US __________________________________________________________________________ 27 VARYING DISRUPTIONS ____________________________________________________________________________ 27 FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 5 of 27  ITEM 4 - ADVISORY BUSINESS ABOUT OUR FIRM FPC Investment Advisory, Inc. is currently registered with the Securities and Exchange Commission ("SEC") as an investment adviser, with its principal place of business located in the state of California. FPC Investment Advisory has been in business since 1994, and its principal owners are Bijan Golkar, Chief Executive Officer & Chief Compliance Officer and Tyler Schalch, Chief Investment Officer. Our Firm was registered with the SEC as an investment adviser in 2018. Our Firm currently has offices located in Petaluma, California and San Jose, California. This brochure is designed to provide detailed and precise information about each item noted in the table of contents. Certain disclosures are repeated in one or more items, and other disclosures are referred to throughout to be as comprehensive as possible on the broad subject matters discussed. Within this brochure, specific terms in either are used as follows: • • • • • • “FPC” and “FPC Wealth” refers to FPC Investment Advisory, Inc. “Firm,” “we,” “us,” and “our” refer to FPC Investment Advisory, Inc. “Advisor,” “Investment Advisor Representative,” and “IAR” refers to our professional representatives who provide investment recommendations or advice on behalf of FPC Investment Advisory, Inc. “You,” “yours,” and “Client” refers to Clients of FPC Investment Advisory, Inc. and its advisors. “Code” refers to our Firm’s Code of Ethics. “CCO” refers to our Chief Compliance Officer, Bijan Golkar. ADVISORY SERVICES WE OFFER Our Firm offers a variety of advisory services, which include discretionary investment management, financial planning, consulting services and assets under advisement, and income tax preparation services. Before rendering any preceding advisory services, Clients must enter into one or more written Investment Advisory Agreements (“Agreements”), setting forth the relevant terms and conditions of the advisory relationship. Our Firm manages portfolios for individuals, high-net-worth individuals and families, estates, trusts, corporations, and charitable organizations. We provide investment management and advisory services to multi-generational families using separately managed accounts under a custodial relationship with an independent brokerage firm. With our discretionary relationship, we will change the portfolio as appropriate to help meet your financial objectives. We trade Client portfolios based on our Firm’s market views and the Client’s financial goals We primarily invest in securities, mutual funds, and exchange-traded funds. As part of the overall investment strategy, a portion of the account may be held in cash, cash equivalents, or money market funds. Cash balances may have a higher concentration and represent a significant portion of your overall portfolio, depending on the current investment outlook or strategy. Clients are advised to promptly notify us if there are changes in their financial situation or if they wish to place any limitations on managing their portfolios. FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 6 of 27  Our Firm can recommend that certain clients utilize margin in the client’s investment portfolio or other borrowing. Our Firm only recommends such borrowing for non-investment needs, such as bridge loans and other financing needs. The Firm’s fees are determined based on the value of the assets being managed gross of any margin or borrowing. Our Firm generally requires a minimum account size of $2,000,000 for advisory accounts. However, from time to time, at our sole discretion, we may accept smaller accounts based on various criteria, such as anticipated future assets, related accounts, and other individual Client circumstances. LEGACY MANAGEMENT SERVICES Our Firm may advise a Client about legacy positions or other investments in Client portfolios. Clients can limit or restrict our trading in these positions. FINANCIAL PLANNING SERVICES Our Firm offers financial planning services, which involve preparing a written financial plan covering specific or multiple topics. We provide full written financial plans, which may address one or several topics: Investment Planning, Retirement Planning, Insurance Planning, Tax Planning, Education Planning, Portfolios, and Allocation Review. Unless otherwise agreed to in writing, the Client is solely responsible for determining whether to implement our financial planning recommendations. Our financial planning services do not involve implementing transactions on your behalf nor include active and ongoing monitoring or management of your investments or accounts. The Client must execute a separate written agreement if the Client elects to implement any of our investment recommendations through our Firm or retain our Firm to monitor and manage investments actively. INCOME TAX PREPARATION SERVICES FPC can provide income tax preparation and tax planning advice in accordance with the rules of the IRS and applicable state laws. Normally, FPC will only prepare income tax returns for individuals and small businesses. Income tax preparation services are normally offered to advisory clients of FPC, but can be extended to other non-advisory customers. FPC can decline to prepare any income tax return due to the complexity and scope involved. There is no requirement that any advisory clients have their income tax returns prepared by FPC. Fees for services rendered are due after the consultations are completed. Tax preparation fees are separate and independent of investment management and financial planning fees. CONSULTING SERVICES & ASSETS UNDER ADVISEMENT Our investment consulting and advisement services are designed to meet our Client’s financial goals, needs, and objectives involving analysis of a Client’s investments, such as variable life insurance and annuity contracts and assets held in employer-sponsored retirement plans, and qualified tuition plans (i.e., 529 plans) held externally from our Firm. In these situations, our Firm may direct or recommend allocating assets among the various investment options available within the product. FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 7 of 27  ROLLOVER RECOMMENDATION DISCLOSURE Our Firm is considered a fiduciary under the Investment Advisers Act of 1940. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and the Internal Revenue Code, as applicable, which are laws governing retirement accounts. We must act in your best interest and not put our interests ahead of yours. At the same time, how we make money conflicts with Client interests. A Client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): • • • • leave the money in the former employer’s plan, if permitted, roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, rollover to an Individual Retirement Account (“IRA”), or cash out the account value (which depending upon the Client’s age, could result in adverse tax consequences). Our Firm may recommend a Client rollover plan assets to an IRA for which our Firm provides investment advisory services. As a result, our Firm and its advisors may earn an asset-based fee on the rolled assets. In contrast, a recommendation that a Client leave their plan assets with their previous employer or rollover the assets to a plan sponsored by a new employer will generally result in no compensation to our Firm. Therefore, our Firm has an economic incentive to encourage a Client to roll plan assets into an IRA that our Firm will manage, which presents a conflict of interest. To mitigate the conflict of interest, there are various factors that our Firm will consider before recommending a rollover, including but not limited to: the investment options available in the plan versus the investment options available in an IRA, fees and expenses in the plan versus the fees and expenses in an IRA, the services and responsiveness of the plan’s investment professionals versus those of our Firm, required minimum distributions and age considerations, and • • • • protection of assets from creditors and legal judgments, • • employer stock tax consequences, if any. The Chief Compliance Officer remains available to address client questions regarding the supervision and oversight of rollover and transfer assets. CLIENT OBJECTIVES & RESTRICTIONS Our Firm tailors our investment management and advisory services continuously to meet the needs of our Clients. We seek to ensure Client portfolios are managed consistently with those needs and objectives in mind. We meet with Clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints, and other related factors relevant to managing their portfolios. Clients may impose reasonable restrictions on managing the accounts if the conditions do not impact the performance of a management strategy. WRAP FEE PROGRAM Our Firm does not sponsor or participate in a Wrap Program. FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 8 of 27  ASSETS UNDER MANAGEMENT As of September 30, 2025, our Firm had a total of $364,599,434 in discretionary assets under management. ITEM 5 - FEES AND COMPENSATION In addition to the information provided in Item 4 – Advisory Business, this section details our Firm’s services and each service’s fees and compensation arrangement. The Client and FPC’s Investment Advisory Agreement will outline and agree upon the exact costs and other terms related to the Client’s Accounts. INVESTMENT MANAGEMENT FEE Our Firm offers investment management services for an annual fee based on the amount of assets under management. Our annual fee typically starts at 1.00%, but we may charge a fee up to 1.25% depending on your assets under management, the scope, and the complexity of your individual financial situation. We have a minimum account size of $2,000,000. We retain the right to waive the minimum account size at our discretion. Assets Under Management First $2,000,000 Next $2,000,000 Next $2,000,000 Next $4,000,000 Over $10,000,000 Annual Fee Rate 1.00% 0.90% 0.70% 0.60% 0.50% Our advisory fee is calculated according to a blended, tiered fee schedule. This means that each portion of a Client’s assets is charged at the rate applicable to that asset tier, rather than applying a single rate to all assets. As an example, for a client with $5,000,000 in assets under management, the fee would be calculated as follows: • 1.00% on the first $2,000,000, • 0.90% on the next $2,000,000, and • 0.70% on the remaining $1,000,000. These tier-based amounts are added together to arrive at the client’s total annual advisory fee. Our annual fee is prorated and charged monthly in advance based on the value of the Client’s assets under management as of the close of business on the last business day of the previous month. Cash and cash equivalents, including money market funds, are subject to the agreed-upon advisory fee. Clients should understand that the advisory fees charged on these balances may exceed the returns provided by cash, cash equivalents, or money market funds, especially in low-interest rate environments. Our annual fee is reasonable in relation to (1) the services provided and (2) the fees charged by other investment advisers offering similar services/programs. Our Firm retains complete discretion to negotiate fees and may waive or impose different fees on any Client. The investment advisory fees will be deducted from your account and paid directly to our Firm by the qualified Custodian(s) of your account. The Client will authorize your account's qualified Custodian(s) to deduct fees from the account and pay such fees directly to our Firm. All account assets, transactions, and advisory fees will be shown on the monthly or quarterly statements provided by the Custodian. You should review your account FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 9 of 27  statements received from the qualified Custodian(s) and verify that appropriate investment advisory fees are being deducted. The qualified Custodian(s) will not verify the accuracy of the investment advisory fees deducted. We may aggregate related Client accounts to calculate the advisory fee applicable to the Client. The investment management agreement will outline the fee charged to a Client and any breakpoints based on the level of assets managed. The fees are subject to change with prior written notice to the Client. Our annual investment advisory fee may be higher than that of other investment advisers that offer similar services and programs. In addition to our compensation, you may incur charges imposed at the mutual fund level (e.g., advisory fees and other fund expenses). Accounts initiated or terminated during a calendar month will generally be charged a prorated fee based on the days the Client account was open during that quarter. Any prepaid, unearned fees will be refunded upon termination of any account. LEGACY MANAGEMENT FEE Managed legacy positions are included within our Firm’s standard investment management fee and are outlined in the executed investment management agreement. FINANCIAL PLANNING FEE Our Firm provides financial planning services under a fixed or hourly fee arrangement. This arrangement charges a mutually agreed-upon fee for financial planning services. The hourly fee range begins at $400, plus expenses. The estimated fee, as well as the total fee to be charged, is based on the scope and complexity of the client engagement. These consultations can include administrative overview, investment allocation review, budgeting, income tax analysis, estate distribution, account setup, and financial planning. Fees charged for our financial planning services are negotiable based upon the type of Client, the services requested, the investment adviser representative providing advice, the complexity of the Client's situation, the composition of the Client's account, other advisory services provided, and the relationship of the Client and the investment adviser representative. The amount of the fee for your engagement is specified in your financial planning agreement with us. At our sole discretion, the Client may be required to pay the fee at the time the agreement is executed with our Firm; however, our Firm does not require or solicit prepayment of more than $1,200 in fees per Client, six months or more in advance. The fee is considered earned upon delivery of the financial plan, and any unpaid amount is immediately due. The Client may pay the fees owed for the financial planning services by submitting payment directly via EFT Transfer via Quickbooks. If the Client elects to pay by automatic deduction from an existing investment account, they will provide written authorization to our Firm for such a charge. If the Client terminates the financial planning services after entering into an agreement with our Firm, the Client will be invoiced and responsible for immediate payment of any hourly financial planning services performed by us before receiving notice of termination. For financial planning services, our Firm performs under a fixed or hourly fee arrangement, the Client will be responsible for paying a pro-rated fixed fee equivalent to the percentage of work that our Firm completed. If there is a remaining balance of any fees paid in advance after deducting fees from the final invoice, those remaining proceeds will be refunded to the Client. FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 10 of 27  TAX PLANNING SERVICE FEES Fees for preparing a tax return will generally range from $400 to $2,500. The fee is dependent on the complexity and work involved in the tax planning. Fees are normally assessed based on the forms associated with the client’s return. The more forms in a return, the higher the associated fee. Advisory clients of FPC are offered a discount on their tax preparation fees. Tax preparation fees are separate and are NOT included as part of any financial planning agreement. All income tax preparation service fees are payable by credit card or EFT Transfer via Quickbooks. In some cases, clients will request to pay by credit card or transfer of funds through an independent third-party payment processor. Bills are sent upon completion of the income tax preparation services and are due and payable upon receipt unless other arrangements are made in advance. CONSULTING SERVICES & ASSETS UNDER ADVISEMENT FEE Our Firm provides consulting services based on an hourly fee arrangement, generally begins at $400 per hour. This arrangement charges a mutually agreed-upon fee for financial planning services. Fees charged for consulting services are negotiable based on the type of Client, the services requested, the investment adviser representative providing advice, the complexity of the Client's situation, the composition of the Client's account, other advisory services provided, and the relationship of the Client and the investment adviser representative. ADMINISTRATIVE SERVICES PROVIDED BY TAMARAC, INC. Our Firm has contracted with Tamarac, Inc. (referred to as “Tamarac”) to utilize its technology platforms to support data reconciliation, performance reporting, fee calculation and billing, research, client database maintenance, performance evaluations, payable reports, web site administration, models, trading platforms, and other functions related to the administrative tasks of managing client accounts. Due to this arrangement, Tamarac will have access to client accounts, but Tamarac will not serve as an investment advisor to our clients. FPC and Tamarac are non-affiliated companies. Tamarac charges our Firm an annual fee for each account administered by Tamarac. Please note that the advisory fee charged to the client will not increase due to the annual fee our Firm pays to Tamarac. The annual fee is paid from the portion of the management fee retained by our Firm. ADDITIONAL FEES & EXPENSES In addition to the advisory fees paid to our Firm, Clients also incur certain charges imposed by other third parties, such as broker-dealers, Custodians, trust companies, banks, and other financial institutions. These additional charges include securities, transaction fees, custodial fees, and Manager charges imposed by a mutual fund or ETF in a Client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Our brokerage practices are described at length in Item 12 below. Neither our Firm nor its supervised persons accept commission compensation for selling securities or other investment products. Further, we do not share any additional fees and expenses outlined above. FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 11 of 27  Our Firm’s investment strategies may include mutual and exchange-traded funds (“ETFs”). Our policy is to purchase institutional share classes of those mutual funds selected for the Client’s portfolio. The institutional share class generally has the lowest expense ratio. The expense ratio is the annual fee that all mutual funds or ETFs charge their shareholders. It expresses the percentage of assets deducted each fiscal year for funds expenses, including 12b-1 fees, management fees, administrative fees, operating costs, and all other asset- based costs incurred by the fund. Some fund families offer different classes of the same fund, and one share class may have a lower expense ratio than another. Mutual fund expense ratios are in addition to our fees; we do not receive any portion of these charges. If an institutional share class is not available for the mutual fund selected, the adviser will purchase the least expensive share class available for the mutual fund. As share classes with lower expense ratios become available, we may use them in the Client’s portfolio or convert the existing mutual fund position to the lower-cost share class. Clients who transfer mutual funds into their accounts with our Firm would bear the expense of any contingent or deferred sales loads incurred upon selling the product. If a mutual fund has a frequent trading policy, the policy can limit a Client’s transactions in fund shares (e.g., for rebalancing, liquidations, deposits, or tax harvesting). All mutual fund expenses and fees are disclosed in the respective mutual fund prospectus. When selecting investments for our Clients’ portfolios, we might choose mutual funds on your account Custodian’s Non-Transaction Fee (NTF) list. This means that your account Custodian will not charge a transaction fee or commission associated with the purchase or sale of the mutual fund. The mutual fund companies that choose to participate in the Client’s Custodial NTF fund program pay a fee to the Custodian to be included in the NTF program. The mutual fund owners ultimately bear the fee that a company pays to participate in the program, as captured in the fund’s expense ratio. When choosing a fund from the Client’s Custodial NTF list, our Firm considers the expected holding period, position size, and expense ratio versus alternative funds. Depending on our Firm’s analysis and future events, NTF funds might not always be in the Client’s best interest. ITEM 6 - PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT Performance-based fees are based on a share of capital gains on or appreciation of the assets in a Client’s account. Our Firm does not accept performance-based or other fees based on a share of capital gains or appreciation of a Client's assets. ITEM 7 - TYPES OF CLIENTS Our Firm provides investment management, investment advice, financial planning, tax planning, and consulting and advisement, to individuals, high-net-worth individuals, families, estates, trusts, corporations, and charitable foundations. Our Firm requires a minimum account value of $2,000,000 to provide advisory services. To reach this account minimum, Clients can aggregate all household accounts. Exceptions may be granted to this minimum for the Client's relationship with the representative. FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 12 of 27  Clients must execute a written agreement with our Firm specifying the advisory services to establish a Client arrangement with us. ITEM 8 - METHODS OF ANALYSIS, STRATEGIES, & RISK OF LOSS METHODS OF ANALYSIS Our Investment Advisory Representatives will generally use the following analysis methods to formulate our investment advice and manage Client assets. However, each IAR can manage its Client’s account as necessary, and their specific analysis method may vary from below. Clients should acknowledge that investing in securities involves the risk of loss, regardless of the strategies, that Clients should be prepared to bear. CYCLICAL TACTILE ASSET ALLOCATION FPC’s method of analysis and investment strategy is a four-step process using Cyclical Tactile Asset Allocation as follows: 1. Analyze the economic conditions globally. 2. Review and evaluate the stock and bond markets globally. 3. Develop and revise four Asset Allocation models which are implemented with no-load mutual funds or ETFs with an emphasis on index funds. 4. Monitor the portfolios on an ongoing basis and rebalance to maintain the allocation with an emphasis toward a long-term investment horizon. Asset Allocation is a diversification strategy that aims to balance risk versus reward by adjusting the percentage of each asset class in a portfolio to optimize an individual’s goals, risk tolerance, and time horizon among various investments. The cyclical approach to tactical asset allocation involves monitoring the economic environment for patterns that have historically led to trends in the stock and bond markets. FPC reviews this economic research along with market valuations to identify asset classes that are anticipated to outperform and underperform their long-term expectations, and then to develop different asset allocation models according a client’s risk profile and objectives. From these models, FPC selects mutual funds or ETFs to implement that allocation with an emphasis on index funds, if available. Once implemented, we rebalance the portfolio on an ongoing basis to maintain that allocation. This approach is called a cyclical economic approach to tactical asset allocation with ongoing rebalancing. We revise these models as economic conditions and market valuations change. A particular asset allocation model is selected for you, based on our discussions with you and our assessment of your objectives and risk tolerance. Accounts are reviewed on an ongoing basis and rebalanced taking into consideration individual client needs (such as withdrawals, capital gains, deposits, etc.). FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 13 of 27  RISK OF LOSS A Client’s investment portfolio is affected by general economic and market conditions, such as interest rates, availability of credit, inflation rates, economic conditions, changes in laws, and national and international political circumstances. Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Our Firm will assist Clients in determining an appropriate strategy based on their tolerance for risk. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. ACTIVE MANAGEMENT RISK Due to its active management, a portfolio could underperform other portfolios with similar investment objectives or strategies. ALLOCATION RISK A portfolio may use an asset allocation strategy to pursue its investment objective. There is a risk that a portfolio’s allocation among asset classes or investments will cause a portfolio to lose value or cause it to underperform other portfolios with a similar investment objective or strategy or that the investments themselves will not produce the returns expected. CAPITALIZATION RISK Small-cap and mid-cap companies may be hindered due to limited resources or less diverse products or services. Their stocks have historically been more volatile than the stocks of larger, more established companies. COMPANY RISK The risk related to a Firm’s business plans, stock valuation, profitability, accounting practices, growth strategy, and other factors particular to a company rather than the overall market. Some of these risks cannot be predicted, such as the retirement or death of a senior executive, which may lead to negative performance in the future. CONCENTRATION RISK Strategies concentrated in only a few securities, sectors or industries, regions or countries, or asset classes could expose a portfolio to greater risk. They may cause the portfolio value to fluctuate more widely than a diversified portfolio. Overexposure to certain sectors or asset classes (e.g., MLPs, REITs, etc.) may be detrimental to an investor if there is a negative sector move. CREDIT RISK The credit rating of an issuer of a security is based on, among other things, the issuer’s historical financial condition and the rating agencies’ investment analyses at the time of rating. An actual or perceived deterioration of the ability of an issuer to meet its obligations would harm the value of the issuer’s securities. FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 14 of 27  CYBERSECURITY RISK Increased Internet use makes a portfolio susceptible to operational and informational security risks. In general, cyber incidents can result from deliberate attacks or unintentional events. Cyberattacks include but are not limited to infection by computer viruses or other malicious software code, gaining unauthorized access to systems, networks, or devices through “hacking” or other means to misappropriate assets or sensitive information, corrupting data, or causing operational disruption. Cybersecurity failures or breaches of third-party service providers may cause disruptions at third-party service providers and impact our business operations, potentially resulting in financial losses; the inability to transact business; violations of applicable privacy and other laws, regulatory fines, or penalties; reputational damage; unanticipated expenses or other compensation costs; or additional compliance costs. Our Firm has an established business continuity and disaster recovery plan and related cybersecurity procedures designed to prevent or reduce the impact of such risks; there are inherent limitations in such plans and systems due in part to the evolving nature of technology and cyberattack tactics. DEFLATION RISK When inflation or expectations are low, the value and income of an account’s investments in inflation-linked securities could fall, resulting in losses. EQUITY RISK Equity instruments are subject to equity market risk, the risk that common stock prices fluctuate over short or extended periods. Equity securities generally have greater price volatility than fixed-income securities. The market price of equity securities may increase or decrease, sometimes rapidly or unpredictably. Equity securities may decline in value due to factors affecting markets generally, industries, sectors or geographic regions represented in those markets, or individual security concerns. EVENT RISK The possibility is that an unforeseen event will negatively affect a company or industry and, thus, increase security volatility. INTEREST RATE RISK When interest rates increase, the value of the account’s investments may decline, and the account’s share value may decrease. This effect is typically more pronounced for intermediate and longer-term obligations. This effect is also typically more pronounced for mortgages and other asset-backed securities since the value may fluctuate more significantly in response to interest rate changes. When interest rates decrease, the account’s current income may decline. LEGACY HOLDING RISK Investment advice may be offered on any investment a Client holds at the start of the advisory relationship. Depending on tax considerations and Client sentiment, these investments will be sold over time, and the assets invested in the appropriate strategy. As with any investment decision, there is the risk that timing with respect to the sale and reinvestment of these assets will be less than ideal or even result in a loss to the Client. FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 15 of 27  LIQUIDITY RISK Low trading volume, large positions, or legal restrictions are some conditions that could limit or prevent a portfolio from selling securities or closing positions at desirable prices. Securities that are relatively liquid when acquired could become illiquid over time. The sale of any such illiquid investment might be possible only at substantial discounts or might not be possible at all. Further, such investments may take more work to value. MANAGEMENT RISK An account is subject to the risk that judgments about the attractiveness, value, or potential appreciation of the account’s investments may prove to be incorrect. If the selection of securities or strategies fails to produce the intended results, the account could underperform other accounts with similar objectives and investment strategies. MARKET RISK Even a long-term investment approach cannot guarantee a profit. Economic, political, and issuer-specific events will cause the value of securities to rise or fall. Because the value of investment portfolios will fluctuate, there is the risk that you will lose money, and your investment may be worth less upon liquidation. Due to a lack of demand in the marketplace or other factors, an account may only be able to sell some or all the investments promptly or may only be able to sell assets at desired prices. MUTUAL FUND OR ETF RISK Our models and accounts may use certain ETFs and mutual funds to invest primarily in alternative investments or strategies. Investing in these alternative investments and strategies may only be suitable for some of our Clients. These include special risks, such as those associated with commodities, real estate, and leverage, selling securities short, use of derivatives, potential adverse market forces, regulatory changes, and potential ill-liquidity. Special risks are associated with ETFs that invest principally in real estate securities, such as sensitivity to changes in real estate values or changes in interest rates and price volatility due to the ETF’s concentration in the real estate market. The risks with mutual funds include the costs and expenses within the fund that can impact performance, change of Managers, and the fund straying from its objective (i.e., style drift). Mutual funds have certain costs associated with underlying transactions and operating costs, such as marketing and distribution expenses and advisory fees. Mutual fund costs and expenses vary from fund to fund and will impact a mutual fund’s performance. Additionally, mutual funds typically have different share classes, as further discussed below, that trade at different Net Asset Values (“NAV”) as determined at the daily market close and have different fees and expenses. REINVESTMENT RISK The possibility of investing a bond’s cash flows at a rate lower than the expected rate of return assumed at the time of buying the bond. Reinvestment risk is high for bonds with long maturities and high coupons. SECTOR RISK The danger is that the stocks of many companies in one sector (like health care or technology) will fall in price simultaneously because of an event that affects the entire industry. FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 16 of 27  ITEM 9 - DISCIPLINARY INFORMATION Registered investment advisers are required to provide information about all disciplinary information that would be material to a Client’s evaluation of our Firm or the integrity of its management. Clients should refer to the Advisor’s Form ADV Part 2B Brochure Supplement. If the Client did not receive the Advisor’s Form ADV Part 2B Brochure Supplement, the Client should contact the Chief Compliance Officer using the information provided on the cover page of this Brochure. Our Chief Compliance Officer is available to address any questions a Client or prospective client may have regarding the above or any information outlined in this Brochure. Our Firm has no legal or disciplinary events that are material to a Client or prospective clients, evaluation of our advisory business, or the integrity of our management services. ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS Our Firm is an independent investment registered adviser that provides only investment advisory services. Our Firm is not engaged in any other business activities and offers no other services except those described in this Brochure. ITEM 11 - CODE OF ETHICS, PARTICIPATION & INTEREST IN CLIENT TRANSACTIONS, & PERSONAL TRADING Our Firm maintains a Code of Ethics to reinforce the fiduciary principles governing our Firm and its employees. The Code, among other things, requires all employees to act with integrity and ethics, and professionalism. Policies against overreaching, self-dealing, insider trading, and conflicts of interest are outlined in our Code. Our Code forbids employees from trading, either personally or on behalf of others, based on non-public material information or communicating non-public material information to others violating the law. Additionally, our Code sets forth restrictions and quarterly attestations on receiving gifts, outside business activities, personal trading activity, maintenance of personal brokerage accounts, and other matters. The Code is appropriately designed and implemented to prevent or eliminate potential conflicts of interest between our Firm, our employees and IARs, Clients, and investors. We always strive to make decisions in our Client's best interest should a conflict of interest arise. Clients should be aware that no set of rules, policies, or procedures can anticipate, avoid, or address all potential conflicts of interest. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS & PERSONAL TRADING Our employees, IARs, and our associated persons are not prohibited from owning or trading securities bought, sold, and recommended to our Clients, provided such personal trading activity complies with the parameters, limitations, and requirements of the Code. Employees, IARs, and associated persons must receive approval from our Firm’s CCO when engaging in reportable securities transactions. Our CCO is responsible for reviewing all employees', IARs, and associated persons' trading when they occur and periodically reviewing trading activity. Our CCO has broad discretion to reject employee trading for any reason. Our Firm’s policies and procedures FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 17 of 27  related to the personal trading activity of employees aim to demonstrate our commitment to placing Clients’ interests ahead of our trading interests. While our Firm does not maintain a proprietary trading account and therefore does not have a direct material financial interest in any securities it recommends to Clients, in certain situations, our Firm’s employees and associated persons may purchase interests in the same securities at the same or different portfolio percentages or risk levels, in which one or more Clients is investing or has invested. Conversely, a Client may purchase interests in security where our employees, IARs, and associated persons are investing or have invested. Any exceptions to the Code require the prior approval of the CCO. We will provide a copy of the Code to any Client or prospective client upon such written or verbal request. Such requests should be directed to our Firm’s CCO at the contact information listed in Item 1 - Cover Page of this Brochure. ITEM 12 - BROKERAGE PRACTICES INVESTMENT MANAGEMENT SERVICES Clients must maintain assets in an account with a “Qualified Custodian,” generally a broker-dealer or bank. If our Firm is asked to give a recommendation, our recommendation is generally based on the broker’s cost and fees, skills, reputation, dependability, and compatibility with the Client. The Client may obtain lower commissions and fees from other brokers. CHARLES SCHWAB & CO. INC. We generally recommend that our Clients utilize Charles Schwab & Co., Inc. Advisor Services ("Schwab"), a registered broker-dealer, Member SIPC, as the qualified Custodian. Our Firm is independently owned and operated and unaffiliated with Schwab. Schwab will hold Client assets in a brokerage account and buy and sell securities when our Firm instructs them. While our Firm recommends that Clients use Schwab as a Custodian, Clients must decide whether to do so and open accounts with Schwab by entering into account agreements directly with them. The Client opens the accounts with Schwab. The accounts will always be held in the Client's name and never in our Firm’s. HOW OUR FIRM SELECTS CUSTODIAN-BROKER Our Firm seeks to recommend a Custodian-Broker who will hold Client assets and execute the transactions on terms that are, overall, most advantageous compared to other available providers and their services. Our Firm considers a wide range of factors, including, among others: • Combination of transaction execution and asset custody services (generally without a separate fee for custody). • Capability to execute, clear, and settle trades (buy and sell securities for Client accounts). • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payments, etc.). • The breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds [ETFs], etc.). FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 18 of 27  • Availability of investment research and tools that assist us in making investment decisions. • Quality of services. • Competitiveness of the price of those services (commission rates, other fees, etc.) and willingness to negotiate the prices. • Reputation, financial strength, and stability. • Prior service to our Firm and our other Clients. • Availability of other products and services that benefit our Firm, as discussed below (see “Products and Services Available To Us From Schwab”). CLIENT BROKERAGE & CUSTODY COSTS For Clients' accounts, Schwab maintains and generally does not charge separately for custody services. However, Schwab receives compensation by charging ticket charges or other fees on trades it executes or settling into Clients' Schwab accounts. In addition to commissions, Schwab charges a flat dollar amount as a "prime broker" or "trade away" fee for each trade that our Firm has executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into a Client’s Schwab account. These fees are in addition to the ticket charges or compensation the Client pays the executing broker-dealer. Because of this, our Firm has Schwab execute most trades for Client accounts to minimize trading costs. Our Firm has determined that having Schwab execute most trades is consistent with our duty to seek the "best execution" of Client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see How Our Firm Selects Custodian-Broker). PRODUCTS AND SERVICES AVAILABLE TO US FROM SCHWAB Schwab Advisor Services™ (formerly called Schwab Institutional®) provides independent investment advisory Firms and Clients with access to its institutional brokerage, trading, custody, reporting, and related services, many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our Clients’ accounts; others help us manage and grow our business. Schwab’s support services generally are available on an unsolicited basis and at no charge to our Firm. These are typically considered soft dollar benefits because there is an incentive to do business with Schwab. Receiving soft dollar benefits creates a conflict of interest. We have established policies in this regard to mitigate any conflicts of interest. We believe our selection of Schwab as Custodian-Broker is in the Clients' best interests. Our Firm will always act in the best interest of our Clients and act as fiduciary in carrying out services to Clients. The following is a more detailed description of Schwab’s support services: SERVICES THAT BENEFIT OUR CLIENTS Schwab's institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client assets. The investment products available through Schwab include some we might not otherwise have access to or would require a significantly higher minimum initial investment by our Clients. Schwab’s services described in this paragraph generally benefit our Clients and their accounts. SERVICES THAT MAY NOT DIRECTLY BENEFIT OUR CLIENTS Schwab also makes other products and services available that benefit our Firm but may not directly benefit our Clients or their accounts. These products and services assist our Firm in managing and administering our Clients’ accounts. They include investment research, both Schwab’s own and that of third parties. Our Firm may use this FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 19 of 27  research to service all or a substantial number of our Client's accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • Provides access to Client account data (such as duplicate trade confirmations and account statements). • Facilitate trade execution and allocate aggregated trade orders for multiple Client accounts. • Provide pricing and other market data. • Facilitate payment of our fees from our Clients’ accounts. • Assist with back-office functions, recordkeeping, and Client reporting. SERVICES THAT GENERALLY BENEFIT ONLY US Schwab also offers other services to help our Firm manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology, compliance, legal, and business needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to our Firm. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide our Firm with other benefits, such as occasional business entertainment for our personnel. OUR INTEREST IN SCHWAB’S SERVICES • The availability of these services from Schwab benefits our Firm because we do not have to produce or purchase them. These services are not contingent upon our Firm committing any specific amount of business to Schwab in trading commissions. We believe our selection of Schwab as Custodian and Broker is in our Client’s best interests. • Some of the products, services, and other benefits provided by Schwab benefit our Firm and may not benefit our Client accounts. Our recommendation or requirement that you place assets in Schwab's custody may be based, in part, on the benefits Schwab provides to our Firm or our Agreement to maintain certain Assets Under Management at Schwab and not solely on the nature, cost, or quality of custody and execution services provided by Schwab. • Our Firm places trades for our Clients' accounts subject to its duty to seek the best execution and other fiduciary duties. Schwab's execution quality may be different from other broker-dealers. • Our Firm does not routinely recommend, request, or require that the Client direct us to execute the transactions through a specified Custodian. Additionally, our Firm typically does not permit the Client to direct brokerage. We place trades for Client accounts subject to our duty to seek the best execution and other fiduciary duties. • We will aggregate trades for ourselves or our associated persons with your trades, providing that the following conditions are met: o Our policy for the aggregation of transactions shall be fully disclosed separately to our existing Clients (if any) and the broker/dealer(s) through which such transactions will be placed. FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 20 of 27  o We will only aggregate transactions if we believe that aggregation is consistent with our duty to seek the best execution (which includes the duty to seek the best price) for the Client and is consistent with the terms of our investment advisory agreement. o No advisory Client will be favored over any other Client; each Client that participates in an aggregated order will participate at the average share price for all transactions in a given security on a given business day, with transaction costs based on each Client's participation in the transaction. o Our Firm will prepare a written statement (“Allocation Statement”) specifying the participating o Client accounts and how to allocate the order among those Clients. If the aggregated order is filled in its entirety, it will be allocated among Clients per the allocation statement; if the order is partially filled, the accounts that did not receive the previous trade's positions should be "first in line" to receive the next allocation. o Notwithstanding the preceding, the order may be allocated on a basis different from that specified if all Client accounts receive fair and equitable treatment. The reason for the difference in allocation will be documented and reviewed by our Firm’s Compliance Officer. Our Firm’s books and records will separately reflect, for each Client account, the orders which are aggregated, and the securities held by and bought for that account. o Our Firm will not receive additional compensation or remuneration of any kind because of the o proposed aggregation; and Individual advice and treatment will be accorded to each advisory Client. BROKERAGE FOR CLIENT REFERRALS Our Firm does not receive Client referrals from any Custodian or third party in exchange for using that broker- dealer or third party. AGGREGATION & ALLOCATION OF TRANSACTIONS Our Firm may aggregate transactions if it believes that aggregation is consistent with the duty to seek the best execution for its Clients and is consistent with the disclosures made to Clients and terms defined in the Investment Advisory Agreement. No Client will be favored over any other Client. Each account in an aggregated order will participate at the average share price (per Custodian) for all transactions in that security on a given business day. If we do not receive a complete fill for an aggregated order, we will allocate the order on a pro-rata basis. If we determine that a pro-rata allocation is not appropriate under the particular circumstances, we will base the allocation on other relevant factors, which may include: • When only a small percentage of the order is executed, with respect to purchase allocations, allocations may be given to accounts high in cash. • Concerning sale allocations, allocations may be given to accounts low in cash. • We may allocate shares to the account with the smallest order, to the smallest position, or to an account that is out of line concerning security or sector weightings relative to other portfolios with similar mandates. • We may allocate one account when that account has limitations in its investment guidelines prohibiting it from purchasing other securities that we expect to produce similar investment results, and other accounts can purchase that in the block. FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 21 of 27  • • If an account reaches an investment guideline limit and cannot participate in an allocation, we may reallocate shares to other accounts. For example, this may be due to unforeseen changes in an account's assets after placing an order. If a pro-rata allocation of a potential execution would result in a de minimis allocation in one or more account(s), we may exclude the account(s) from the allocation. • Our Firm will document the reasons for any deviation from a pro-rata allocation. In certain cases, client requests or specific needs will trigger an unplanned transaction in a security where an aggregate transaction occurred previously during the day. Under these circumstances, client transactions will be excluded from the block transaction and ultimately receive differing pricing. TRADE ERRORS Our Firm has implemented procedures designed to prevent trade errors; however, our Firm cannot always avoid Client trade errors. Consistent with our Firm's fiduciary duty, it is our Firm’s policy to correct trade errors in a manner that is in the Client's best interest. In cases where the Client causes the trade error, the Client will be responsible for any loss resulting from the correction. Depending on the specific circumstances of the trade error, the Client may not be able to receive any gains generated due to the error correction. In all situations where the Client does not cause the trade error, the Client will be made whole, and we would absorb any loss resulting from the trade error if our Firm caused the error. If the Custodian causes the error, the Custodian will cover all trade error costs. If an investment error results in a gain when correcting the trade, the gain will be donated to charity. Our Firm will never benefit or profit from trade errors. DIRECTED BROKERAGE Our Firm does not routinely recommend, request, or require that the Client direct us to execute the transaction through a specified broker-dealer. Additionally, our Firm typically does not permit the Client to direct brokerage. Our Firm places trades for Client accounts subject to its duty to seek the best execution and other fiduciary duties. ITEM 13 - REVIEW OF ACCOUNTS CLIENT REVIEWS Our Firm reviews Client accounts and financial plans periodically. Our IARs will monitor Client accounts regularly and offer to perform annual reviews with each Client on an annual basis. All accounts are reviewed for consistency with Client investment strategy, asset allocation, risk tolerance, and performance. More frequent reviews may be triggered by changes in an account holder’s personal, tax, or financial status. Geopolitical and macroeconomic-specific events may also trigger reviews. Our recommendations depend on the information provided by the Client. Our Client must notify our Firm of any situation that would impair our ability to manage our Client accounts properly. FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 22 of 27  The Client receives a copy of each trade confirmation (unless the Client has authorized the Custodian to suppress the confirmations) and the standard written account statement from the qualified account Custodian every quarter. ITEM 14 - CLIENT REFERRALS & OTHER COMPENSATION BROKERAGE PRACTICES As disclosed under Item 12 Brokerage Practices, we participate in the Custodian’s institutional customer programs, and we may recommend a Custodian to our Clients for custody and brokerage services. There is no direct link between our participation in the program and the investment advice we give to our Clients. However, we receive economic benefits through our participation in the program that is typically not available to any other independent advisors participating in the program. These benefits include the following products and services (provided without cost or at a discount): • Receipt of duplicate Client statements and confirmations. • Research-related products and tools. • Consulting services. • Access to a trading desk serving adviser participants. • Access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to Client accounts); • The ability to have advisory fees deducted directly from Client accounts. • Access to an electronic communications network for Client order entry and account information. • Access to mutual funds with no transaction fees and certain institutional money Managers. • Discounts on compliance, marketing, research, technology, and practice management products or services provided to us by third-party vendors. Custodians may also have paid for business consulting and professional services received by some of our IARs. Some of the products and services made available by Custodians through the program may benefit us but may not benefit your account. These products or services may assist us in managing and administering Client accounts, including accounts not maintained at our recommended Custodian. Other services made available by the Custodian are intended to help us manage and further develop our business enterprise. The benefits our Firm or our IARs receive through participation in the program do not depend on the amount of brokerage transactions directed to the Custodian. Due to these arrangements, our Client does not pay more for assets maintained at Schwab. As part of our fiduciary duties to Clients, we always endeavor to put our Client's interests first. Clients should be aware, however, that receiving economic benefits from our Firm or our IARs in and of itself creates a conflict of interest because the cost of these services would otherwise be borne directly by us. These arrangements could indirectly influence our choice of Custodian for custody and brokerage services. Clients should consider these conflicts of interest when selecting a Custodian. The products and services provided by the Custodian, how they benefit us, and the related conflicts of interest are described above. OTHER PROFESSIONALS Our Firm may refer business to estate planning attorneys, accountants, insurance brokers, and other professionals. However, we do not receive monetary or other material compensation for referring Clients to such professionals. We also do not pay any person or firm commissions or other items of material value for referring FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 23 of 27  Clients to us. If we receive or offer an introduction to a Client, we do not pay or earn a referral fee, nor are there established quid pro quo arrangements. Each Client can accept or deny such referral or subsequent services. ITEM 15 - CUSTODY Regulators have defined custody as having access or control over Client funds or securities. As it applies to our Firm, we do not have physical custody of funds or securities. FEE DEDUCTION Our Firm is deemed to have constructive custody over those Client accounts where our Firm is able to deduct our fees directly from the Client account. As long as we comply with certain regulatory requirements, this constructive custody does not mandate that our Firm undergo a surprise audit for those accounts. Our Clients receive account statements directly from the qualified Custodian at least quarterly. Our Firm may send Clients quarterly reports that our Firm produces using our portfolio accounting system, Tamarac, Inc. We strongly urge our Clients to compare such reports with the statements received from the qualified Custodian. Furthermore, when our Firm calculates our investment management fees and instructs the Custodian to remit these fees to us directly from Clients’ accounts, the Custodian does not verify our calculation of fees. Our Firm performs quarterly testing to ensure that our fees are charged per the Client’s Investment Advisory Agreement on file with our Firm. STANDING LETTERS OF AUTHORIZATION (“SLOA”) Additionally, our Firm is deemed to have custody of the Client’s funds or securities when you have standing authorizations with their Custodian to move money from your account to a third-party (“SLOA”) and, under that SLOA, it authorizes us to designate the amount or timing of transfers with the Custodian. The SEC has set forth standards to protect your assets in such situations, which we follow. We do not have a beneficial interest in any of the accounts we are deemed to have Custody of where SLOAs are on file. In addition, account statements reflecting all activity on the account(s) are delivered directly from the qualified Custodian to each Client or the Client’s independent representative at least monthly. You should carefully review those statements and are urged to compare the statements against reports received from us. When you have questions about your account statements, contact us, your Advisor, or the qualified Custodian preparing the statement. ITEM 16 - INVESTMENT DISCRETION DISCRETIONARY AUTHORITY Upon receiving written authorization from the Client, our Firm provides discretionary investment advisory services for Client accounts. For discretionary accounts, before engaging our Firm to provide investment advisory services, you will enter into a written Investment Advisory Agreement with us granting our Firm the authority to supervise and direct, on an ongoing basis, investments per the Client's investment objective and guidelines. In addition, our Client will need to execute additional documents required by the Custodian to authorize and enable our Firm, in its sole discretion, without prior consultation with or ratification by our Client, to purchase, sell or exchange securities in and for your accounts. We are authorized, at our discretion and FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 24 of 27  without prior consultation with the Client, to (1) buy, sell, exchange, and trade any stocks, bonds, or other securities or assets and (2) determine the amount of securities to be bought or sold and (3) place orders with the Custodian. Any limitations to such discretionary authority will be communicated to our Firm in writing by you, the Client. The limitations on investment and brokerage discretion held by our Firm are: • For discretionary accounts, we require that we be given the authority to determine which securities and the amounts to be bought or sold. • Any limitations on this discretionary authority shall be in writing as indicated in the Investment Advisory Agreement. Clients may change or amend these limitations as required. ITEM 17 - VOTING CLIENT SECURITIES PROXY VOTING We vote proxies that, in our reasonable judgment alone, we determine affect the value of your account. In doing so, we generally cast proxy votes in favor of proposals that increase shareholder value and generally cast against proposals having the opposite effect. Decisions on proxy voting are usually made after a discussion by appropriate persons within our firm. Neither FPC nor any related person has a material relationship with the companies in which clients are invested which would pose a conflict of interest. The proxies are voted in prudent and diligent fashion and only after careful evaluation of the issue presented on the ballot. You can provide direction regarding any proxy solicitation. You can elect to retain the authority to vote the proxies yourself. In that case, you will receive proxies and other related paperwork directly from your custodian. Upon request, we will provide guidance about voting a specific proxy solicitation. You can request a copy of our Proxy Policies and Procedures and/or information about how a proxy was voted at any time by contacting FPC via email or telephone. CLASS ACTION LAWSUITS Our Firm does not advise or instruct Clients on whether to participate as a member of class action lawsuits and will not automatically file claims on the Client’s behalf. However, if a Client notifies us that they wish to participate in a class action, we will provide the Client with transaction information about the Client’s account that is required to file a proof of claim in a class action. FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 25 of 27  ITEM 18 - FINANCIAL INFORMATION FINANCIAL CONDITION Our Firm has no financial commitment that impairs its ability to meet Client contractual and fiduciary obligations and has not been the subject of a bankruptcy proceeding. We do not require or solicit prepayment of more than $1200 in fees per Client six months or more in advance. Therefore, we are not required to include a balance sheet for the most recent fiscal year. ADDITIONAL INFORMATION PRIVACY POLICY Our Firm collects non-public personal information about Clients from information received on applications or other forms and information about Client transactions with firm affiliates, others, or our Firm. We do not disclose any nonpublic personal information about current or former Clients except as permitted by law or to provide services. Firm employees have limited access to Clients' data based on their responsibilities to provide products or services to Clients. Our Firm maintains physical, electronic, and procedural safeguards in compliance with federal standards to protect Client information. If the IAR servicing a Client account leaves our Firm to join another firm, the IAR is not permitted to retain copies of specific Client information. A copy of our Firm's Privacy Policy is given to each Client at account opening, upon request, and provided annually. You can also download this privacy policy at any time by visiting our website. OPTING OUT If a Client does not want an IAR to retain copies of the Client's non-public personal information when the IAR leaves our Firm to join another firm, the Client can contact our Compliance Department by calling (707) 795- 0500. BUSINESS CONTINUITY PLAN Our Firm has developed a Business Continuity Plan to address how our Firm will respond to events that significantly disrupt the operation of our business. Since the timing and impact of disasters and disruptions are unpredictable, our Firm will be flexible in responding to actual events as they occur. Within 24 hours after a significant business disruption, our Firm plans to quickly recover and resume business operations and respond by safeguarding employees and property, making a financial and operational assessment, protecting our Firm’s books and records, and allowing Clients to transact business. Given the scope and severity of the significant business disruption, our business continuity plan is designed to permit our Firm to resume operations as quickly as possible. Our Firm’s business continuity plan addresses: data back-up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 26 of 27  physical location of employees; critical supplier, contractor, bank, and counter-party impact; regulatory reporting; and assuring Clients’ prompt access to their funds and securities if our Firm is unable to continue as a business. Our Firm backs up essential records in a geographically separate area. At the same time, every emergency poses unique problems based on external factors, such as the time of day and the severity of the disruption. Its objective is to restore operations and be able to complete existing transactions and accept new transactions and payments within four hours of the disruptive event. Client orders and requests for funds and securities could be delayed during this period. CONTACTING US If a Client cannot contact our Firm at (707) 795-0500 after a significant business disruption, please visit the website at www.fpcwealth.com to review updated contact information. VARYING DISRUPTIONS Significant business disruptions can vary in scope, such as disruption that affects only our Firm, a single building housing our Firm, the business district where our Firm is located, the city where our Firm is located, or the whole region. Within each of these areas, the severity of the disruption can also vary from minimal to severe. In a disruption to only our Firm or a building housing our Firm, our Firm will transfer operations to a local site when needed and expect to recover and resume business within 24 hours. In a disruption affecting our Firm’s business district, city, or region, our Firm will transfer operations to a site outside the affected area and recover and resume business within three (3) days. In either situation, our Firm plans to continue the business, transfer operations to its clearing firm if necessary, and provide Clients with instructions on contacting our Firm through its parent company’s website: www.fpcwealth.com. If the significant business disruption is so severe that it prevents our Firm from remaining in business, our Firm will ensure the Client’s prompt access to their funds and securities. This information is provided solely to Clients of our Firm, and no further distribution or disclosure is permitted without the prior written consent of our Firm. No person other than our Firm Clients can rely on any statement herein. Our Firm’s Business Continuity Plan is reviewed and updated regularly and is subject to change. Please visit the website at www.fpcwealth.com for the most current copy of this disclosure. You can request an updated copy by contacting our Firm at (707) 795-0500 or writing our Firm at the following: FPC Investment Advisory, Inc. 1465 N. McDowell Blvd. # 170 Petaluma, CA 94954 FPC Investment Advisory, Inc. 1465 North McDowell Blvd., Suite 170, Petaluma, CA 94954 P/ (707) 795-0500 | F/ (707) 703-4414 November 2025 | www.fpcwealth.com Page 27 of 27